Article 25: Mutual Agreement Procedure: Where a taxpayer believes that the treatment by contracting states(s) is not in accordance with the provisions of the tax treaty competent authorities of both countries should…
Category: Model Tax Convention
Article 26: Exchange Of Information (Model Tax Convention)
Article 26: Exchange of Information: In order to complete tax cases, a country may require certain information which may be available with the treaty partner. Article 26 Provides For: the information which…
Article 26: Exchange Of Information (Model Tax Convention)
Article 26: Exchange of Information: In order to complete tax cases, a country may require certain information which may be available with the treaty partner. Article 26 Provides For: the information which…
Analysis Of Article 21 & 23: Model Tax Convention
Article 21: Other Income: This Article deals with taxation of items of income which are not specifically taxable under any other specific Article. Key differences are as under: OECD approach envisages that…
Article 14: Independent Personal Services In Model Tax Convention
Article 14: Independent Personal Services Article 14 is only present now in the UN Model. It was deleted from the OECD Model. The Effect of deletion of Article 14 is that income…
Article 13 Of Model Tax Convention: Capital Gain Tax
Article 13 :Capital Gain: This is the most commonly used Article and it provides for the taxation of income arising from transfer of a capital asset, including transfer of shares. The right…
Commentaries Of Article 12 & 12A : Model Tax Convention
Article 12: Royalties This Article provides the right of Contracting States to tax income from royalty Key differences between the two Models are as follows As per the OECD Model, royalties arising…
Article 11 : Interest Treatment in Model Tax Convention
Article 11: Interest Paragraph 1 of this Article provides the right to Residence State to tax interest. Paragraph 2, however, also confers right to the Source State to tax interest. Generally, the…
Analysis On Article 7 : Model Tax Convention
Article 7: Business Profits: Business profits of an enterprise can only be taxed by the Residence State. Right of Source State to tax business profits of an enterprise only exists if a…
Article Number- 5 : Permanent Establishment
Article 5: Permanent Establishment: Article 5 (1) states the “basic rule” for a Permanent Establishment and expresses the primary meaning of Permanent Establishment The definition of Permanent Establishment in Article 5 does…
Article Number- 4 : Residence In Model Tax Convention
Article 4: Residential Status: Residential status of any person shall be determine as per domestic tax law of that country. If any person become resident of both the country then his residential…
Model Tax Convention Article Number- 2 ( Taxes Covered)
Article 2: Taxes Covered: Taxes On Income And Capital – The MTC apply to taxes on income and on capital imposed on behalf of a CS or of its political subdivisions or…
Model Tax Convention Article Number- 1 ( Persons Covered)
Article 1: Persons Covered: The OECD and UN Model Convention would apply to persons who are residents of one or both of the Contracting States. Fiscally transparent entity – Income derived by…
Model Tax Convention [ OECD Vs UN Model Tax Vs US Model Tax ]
Model Tax Convention: The significant model conventions have been briefly discussed hereunder OECD Mode: OECD Model is essentially a model treaty between two developed nations. This model advocates the residence principle, i…
